Site Allocations Plan March 2016

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Comment Information

Comment Information
Document Section Site Allocations Plan March 2016 Sustainability Appraisal Sustainability Appraisal [List all comments on this document part]
Comment ID 14590529//29
Respondent Persimmon Homes Severn Valley [List all comments by this respondent]
Response Date 28 Apr 2016
  1. Sustainability Appraisal

The Sustainability Appraisal in its current format is not fit for purpose and would be unsound. We note that table 1 of the main report sets out sustainability appraisal framework objectives and these are repeated in the assessment criteria for residential site allocations headline documents. However, the A3 spreadsheet assessments of the sustainability of each site assessed in each village uses different headings as follows:

Sustainability Objective

Table 1

Assessment Table


Education facilities

Community facility


Opportunities to work locally

Primary education/ secondary education


Access to town centres and services



Reduce poverty

Nearest town

In paragraph 3.9 of the Main Report we note that it says that search for suitable development sites is based on a sequential approach ‘with sites in or on the edge of towns favoured over those in the villages.’ It then sets out balancing criteria. However we note that the reality is that Green Belt is treated as an absolute constraint, whereas there may be sustainable sites within Green Belt on the edges of towns. This is an important sustainability consideration and the constraint applied should be recognised.

  1. Comments on Background Document ‘Assessing the Sustainability and Settlement Hierarchy of Rural Settlements in North Somerset’

The document sets out a comprehensive assessment of the sustainability of villages in North Somerset. At this stage it is not possible to comment on the sustainability characteristics or the way they have been assessed for each settlement without carrying out further work. However, using the assessment as presented we have the following comments.

Appendix D helpfully sets out in a summary table the relative sustainability of each settlement and presents this as a hierarchy. However, when this hierarchy is compared with the proposed allocations in each village, it is clear that there is no correlation between the sustainability hierarchy and the actual allocations. The document contains no overall sustainability assessment for each village against its potential development. In addition, there is no evidence of how the Appendix D table setting out the relative settlement sustainability this appraisal has been used to identify suitable allocations.

In particular, the document clearly identifies Backwell as the most sustainable village in North Somerset, whereas Churchill and Yatton are identified as environmentally sensitive. In total, Backwell has 6 green RAGs and 2 ambers, Winscombe 1 green and 7 ambers, Churchill 7 ambers and 1 red and Yatton 3 greens, 4 ambers and 1 red. There is clearly no correlation between the sustainability assessment and the allocations for each village, which is further illustrated in the table below.

Relative Settlement Sustainability Compared with Total Housing Allocations


Total RAG Rating

Proposed Dwellings




Long Ashton




































Backwell is by far and away the most sustainable village. Applying the points system set out in Appendix D to the RAG Assessments for each village shows Backwell on 22 points, a full 3 points ahead of the next most sustainable village Long Ashton. And yet the allocation in Backwell is only 65 units, despite there being capacity adjoining the previously defined settlement boundary, without requiring use of Green Belt or landscape designations. The allocation at Churchill (8th place, 15 points) is 237% above Backwell and at Winscombe in fourth place (18 points) 206% above Backwell.

Then, why is it appropriate for no allocations in four of the nine Service Villages or why Yatton, in third place in the hierarchy should accommodate more than three times more dwellings than the next highest allocation?

Thirdly Bleadon is in last place but is allocated 42 dwellings.

We note that four of the Service Villages receive a red RAG assessment for being environmentally sensitive and yet two of them (Yatton and Churchill) have substantial allocations.

  1. Assessment of Appendix C – Facilities Schedule for Rural Villages in North Somerset

We have not carried out a comprehensive assessment of Appendix C, but in the first instance compared Backwell (first in the hierarchy with an allocation of 65) with Churchill (eighth in the hierarchy, 219 allocated). This reveals:

  • Backwell receives a red RAG rating under the heading Tertiary/Post Secondary Education and yet this category does not appear in the Churchill assessment at all;
  • Backwell has a pharmacy in the village (green) whereas there is none in Churchill (red);
  • Backwell has a choice of two large supermarkets (the table only identifies one) within 3.5 km (amber) whereas Churchill is assessed as red;
  • Churchill has no other food shops, no non-food shops, no banks or ATM facilities and only one other shop, compared with 14 additional shops in Backwell;
  • Churchill has one restaurant compared with six in Backwell;
  • A facility which is a substantial sustainability benefit in Backwell and the ability to easily access a full range of services and facilities is Nailsea and Backwell Station, whereas Churchill has no access to trains;
  • In addition three of the Service Villages (Claverham, Long Ashton and Yatton) rely on Backwell School for secondary education and Claverham and Long Ashton are reliant on Backwell leisure centre.

This demonstrates that having ranked the villages in sustainability terms there is no attempt to use this to make allocations according to the local facilities in each village. Neither is there any assessment of the quality of the facilities. There is no identification of key facilities or scoring to give recognition to the relative importance of different facilities. Other than simply listing facilities the only assessment is the distance a facility is from the village. By doing this it accepts that distance to facility affects sustainability, but once classified as being beyond 5 km all facilities are classified the same. Also it does not reflect the distance people will be willing to travel for different facilities. Given the relatively good access to facilities throughout North Somerset these issues may have minimal impact in some cases, but there is no evidence of an attempt to assess this in the sustainability appraisal in order to justify leaving it out.

Overall there is absolutely no correlation between the sustainability assessment of villages, sites and the allocations made in the plan. Therefore the plan is unsound.